Filed under: Current Issues in Credit Unions | Tags: interest rate risk, local checks, Regulation E, Regulation Z, SAFE Act
We have a new logo and a new co-host! Anthony Demangone joins the crew permanently starting this month! Anthony along with Faith, Brian, Hal and Rob discuss the following:
–Reg Z final rule and other miscellany like floor rates on credit cards.
–Reg E and overdraft services tips from Brian
–Funds availability in the absence of “local checks.”
–Interest Rate Risk and other types of portfolio concentration.
–SAFE Act exceptions
The CIiCU hosts are:
Brian Witt
Hal Scoggins
Farleigh Wada Witt,
Attorneys at Law
121 SW Morrison Street, Suite 600
Portland, Oregon 97204
Telephone: 503-228-6044 503-228-6044 503-228-6044 503-228-6044
Fax: 503-228-1741
http://www.fwwlaw.com
Guy Messick
Katherine Weber
Messick & Weber P.C.
The Madison Building, 108 Chesley Drive
Media, Pennsylvania 19063-1712
Telephone: 610-891-9000 610-891-9000 610-891-9000 610-891-9000
Fax: 610-891-9008
http://www.cusolaw.com
Faith Anderson
American Airlines Credit Union
P.O. Box 619001
MD 2100
DFW Airport, TX
75261-9001
(800) 533-0035 (800) 533-0035 (800) 533-0035 (800) 533-0035
https://www.aacreditunion.org/default.asp
Anthony Demangone
AFCU Director of Regulatory Compliance
NAFCU – National Association of Federal Credit Unions
3138 10th Street North
Arlington, VA 22201-2149
Telephone: 703-522-4770 703-522-4770
Toll-Free: 800-336-4644 800-336-4644
Fax: 703-524-1082
http://www.nafcu.org/
Robert Rutkowski
Shareholder
Weltman, Weinberg & Reis Co., L.P.A.
323 W. Lakeside Avenue, Suite 200
Cleveland, Ohio 44113
Telephone: 216-739-5004 216-739-5004 216-739-5004 216-739-5004
Fax: 216-739-5642
http://www.thatcreditunionblog.com
http://www.weltman.com
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Filed under: Uncategorized
Today’s blog comes courtesy of Denise Wymore, owner of consulting service for cooperatives, Denise Wymore, LLC.
Breaking Into New Markets With Old Habits
By: Denise Wymore
You know that old joke about the two shoe salesmen who travel to a primitive village to check out a new market? One salesman comes back dejected and says that it’s hopeless because the people don’t wear shoes. The other one is really excited because there’s no competition and the market is wide open.
Some of the most successful salesmen in the last decade gave us products we didn’t know we needed. Many of the most popular we didn’t really need, but we wanted them. Think of the latest generation iPod Nano complete with video capabilities. Or the iPhone app Shazam that let’s you settle bar bets about the song that is playing on the juke box. Or the soy chai latte with extra foam.
Our organizational chart is designed to discourage innovation. Where’s the product development? Where’s research? Where’s the think tank and prototype lab? Instead of creating the demand, we tend to wait for it, read about it, review it, meet about it, budget for it, plan to plan to integrate it, legislate it and then…..market it.
I give you five different kinds of checking accounts. One to meet your needs. There’s the basic, direct, exclusive, select and of course the teen account.
Sound familiar?
Most marketing programs tackle product development around a broad demographic audience. A psychographic approach seeks to solve a problem for a particular (read narrow) group of people with a common bond.
Imagine offering a product that your competition wouldn’t dare offer. Like the Homeroom mortgage loan at OnPoint Credit Union that is only available to those working in an accredited educational institution.
The original credit union model did not target demographics. It targeted a small group of people – usually employees – who pooled their resources to help each other obtain what traditional banking would not approve. These tiny financial cooperatives had no competition. They made banks irrelevant. And that’s why they were so successful.
There was no credit score, no stand-in software to judge; instead their peers determined the character of the person and the purpose of the transaction. It was like borrowing money from your friends and co-workers, only less awkward. And with that came the shame of default. You paid your credit union first. Always.
Fast forward to the lives, works, worships in an 8-county field of membership. That’s a territory, not a target. The thinking was, if you become full service, you will have a better chance at becoming their PFI, so let’s keep adding services. The problem with that – the services added were already available. Take business accounts for example. Your credit union decides to offer them, to an audience that already has several options.
What’s the solution? Solve a problem. That’s it. The most innovative companies solved a problem that many people didn’t know they had. The obstacles existed, but were tolerated. Kind of like banker’s hours.
Perfect example of problem solving as innovation tool: Blockbuster Video. They started out renting video recorders and videos and selling popcorn, sodas and candy. It solved the problem of families spending way too much money on going to the movies. Even if you rented the recorder, it was still cheaper.
Blockbuster suffered from inertia however and created a problem that Netflix gladly and profitably solved. The late fees and driving in the rain to pick up or drop off the movie and not having the movie in stock. Then TiVo comes along and trumps Netflix by offering instant downloads of movies from Amazon.com, and of course Netflix and Blockbuster. The digital movie file is, to some degree, becoming a commodity.
The simplest way to break into a new market, is to solve a problem for a narrow audience. The story at the beginning, about the shoe salesman, did just that. These folks didn’t have shoes, didn’t know they needed them, and shoes definitely solve problems. They will market your product for you with positive word-of-mouth. Before you know it, everyone in the village will be wearing shoes – your shoes!
So, what’s your problem?
Read more about Denise here.
Filed under: bankruptcy
The following is an article reprinted with permission from the upcoming Winter 2010 edition of trendline (WWR’s bankruptcy newsletter):
Avoiding Preference Risk
By: Kevin C. Susman, Associate
Creditors doing business with entities they suspect are on the verge of filing for bankruptcy protection need to be aware that they may be required to return the payments received from that entity within the 90 days preceding a bankruptcy filing. Whether you are a party to litigation entering into a settlement agreement, a trade creditor contemplating a compromise of a delinquent account, a lender negotiating a workout, or simply conducting business as usual, all dealings with financially troubled parties should be approached with an eye on avoiding preference risk.
Section 547 of the Bankruptcy Code permits a debtor-in-possession in a Chapter 11 (reorganization) case, or a bankruptcy trustee in a Chapter 7 (liquidation) case, to recover certain payments made to the debtor’s general creditors within 90 days (or one year if the payments went to “’insiders’ of the debtors”) prior to the petition filing date for the bankruptcy. Such payments are considered “preference” payments, or just “preferences”.
The purpose of this portion of the Code is to discourage creditors from taking extraordinary collection measures against a potential debtor in the immediate, pre-bankruptcy period. In at least some cases, if creditors do not panic, the debtor can successfully work through the financial issues that trouble it and resume ordinary payment of its bills. But if creditors push, there is a perceived rush on the debtor to collect everything possible.
For example, preferential payments to the debtor’s “favorite” creditor who holds a personal guarantee by the debtor’s principal or to the creditor who can hurt the debtor the most do not reflect the bankruptcy policy of equality of treatment for all creditors. So bankruptcy law can compel a creditor to disgorge monies received in excess of its fair share of the debtor’s assets.
If a creditor receives a letter or call from debtor’s bankruptcy counsel about a potential preference claim the creditor should not automatically refund the payment(s). There are potential defenses against repayment and, in any event, it’s a negotiation game, particularly if the demand is for a relatively small sum. If negotiation does not settle the claim, the debtor or the trustee can file suit against you in the bankruptcy court. Even if suit is filed, the claim can probably still be settled by negotiation.
The Bankruptcy Code provides several defenses to preference liability in order to encourage creditors to continue conducting business with a financially troubled debtor in the hope of avoiding a bankruptcy filing. The three most common defenses are:
(i) The contemporaneous exchange for new value,
(ii) The subsequent new value, and
(iii) The ordinary course of business defenses.
The first of these three defenses prevents recovery of a payment when the transfer was intended by the debtor and creditor to be a contemporaneous exchange for new value given to the debtor and when such exchange was in fact substantially contemporaneous. New value is defined by the bankruptcy code as money or money’s worth in goods, services, or new credit, or a release by a transferee of property previously transferred, but does not include an obligation substituted for an existing obligation.
The “new value” rule requires that you demonstrate an essentially contemporaneous exchange of value between you and the creditor. After learning of a debtor’s bankruptcy filing, a creditor should account for all payments received within the 90 days preceding the filing and match those payments to goods shipped or services provided after the date of the oldest payment received within the preference period. This will allow the creditor to analyze the extent of its new value defense and potential liability to a preference attack, aiding in a cost-effective resolution of any preference demand.
The “ordinary course” defense protects recurring, customary credit transactions that are incurred and paid in the ordinary course of the debtor’s business and the creditor’s business. To successfully employ this defense, it is imperative a creditor maintain detailed records of the dates that payments are received in relation to the dates invoices are generated in order to show that the pattern of payments received within the 90-day preference period is comparable to either industry statistics or the prior payment history between the parties. This defense highlights another common mistake of creditors, which is to restrict credit terms upon discovering a debtor is experiencing financial difficulty. Several courts have found that payments received after a creditor began restricting credit terms were not made within the ordinary course of business between the creditor and debtor. Rather than tighten or more strictly enforce credit terms, creditors should require prepayment in order to avail themselves of the new value defenses discussed above.
Although it may be impossible to completely eliminate all preference risk when dealing with a distressed entity, especially when drafting a settlement or workout agreement, there are strategies that can help reduce such risk. Further, given the available statutory defenses, if a payment received within the preference period is attacked as a preference, a compromise can likely be reached with the trustee that would prove more favorable to the creditor than the recovery that could be expected through the bankruptcy claims process.
Kevin C. Susman is an Associate in the Legal Action Recovery department of the Cleveland office. He can be reached at (216) 685-4298 or ksusman@weltman.com.
Filed under: bankruptcy
The following is an article reprinted with permission from the upcoming Winter 2010 edition of trendline (WWR’s bankruptcy newsletter):
Federal Rules of Bankruptcy Procedure Amended December 1, 2009
By: Holly C. Thurman, Associate
The Federal Rules of Bankruptcy Procedure were amended effective December 1, 2009. Throughout the rules, the deadlines and time periods that have been amended are modified in the following manner:
∙ 5 day periods become 7 day periods
∙ 10 day periods become 14 day periods
∙ 15 day periods become 14 day periods
∙ 20 day periods become 21 day periods
∙ 25 day periods become 28 day periods
The following revised rules are the most frequently referred to timelines and deadlines in creditor bankruptcy practice:
1) Stay of Order Granting Relief from the Automatic Stay: An order granting a motion for relief from an automatic stay is stayed until the expiration of 14 days after the entry of the order. Formally, relief from stay wasn’t effective for 10 days from the date of the order and the amendments have extended that time period to 14 days.
2) Time for Filing Notice of Appeal: The notice of appeal shall be filed with the clerk within 14 days of the date of entry of the judgment, order, or decree appealed from. Formally, the appellant had 10 days from the date of entry of the order to appeal.
3) Briefs and Appendix; Filing and Service: Unless the district court or the bankruptcy appellate panel by local rule or by order excuses the filing of briefs or specifies a different time limit, the appellant shall serve and file a brief within 14 days after entry of the appeal on the docket. Appellant formally had 15 days to file a brief from the date of the entry of the appeal on the docket.
4) Computing time: Per the amendments, when computing time periods, the moving party is to count everyday, including intermediate Saturdays, Sundays, and legal holidays. The former rules required we exclude those days when computing time periods and deadlines.
5) Computing and Extending time for Motions—Affidavits: A motion and notice of hearing must be served no later than 7 days before the time specified for such hearing, unless a different period is fixed by these rules or by an order of the court. The rules formally required that the motion and notice of hearing be served 5 days prior to the specified hearing, unless the court specified otherwise. Most Courts specify a time to serve the notice that is earlier than 7 days prior to the hearing, and usually the Courts require the notice to be served immediately upon receipt.
These changes impact deadlines used in everyday practice. Creditors must be aware of the new timelines and guidelines and use them to effectively administrate orders and other notices issued by the Court.
Holly C. Thurman is an Associate in the Bankruptcy department of the Pittsburgh office. She can be reached at (412) 338-7105 or hthurman@weltman.com.
On January 13, I had the pleasure of appearing on The Ray Lucia Radio Show. A friend of mine arranged this and I definitely enjoyed the experience. Of course, who wouldn’t enjoy the opportunity to talk about Regulation Z and the Credit CARD Act?! I can’t get enough of that. Moreover, with the Federal Reserve’s new Final Rule topping nearly 1200 pages, I have a lot of reading to do too. It’s like getting a free novel to read!
Mr. Lucia’s show addresses “Your Money, Your Business, Your Life.” He and his radio show team are consummate pros at putting on a successful broadcast. My experience with Internet radio is starkly different in terms of pacing, energy (and effort). When you do a podcast, you have time to edit and the recording part is kind of relaxed. Not so with live radio. You have to stand and deliver and there’s no retake and no editing. Mr. Lucia does a 3-hour show Monday through Friday. I can only imagine the amount of effort that goes into something like that. Moreover, like me, Mr. Lucia has a day job. He’s a certified financial planner with his own firm.
He’s also written a book on how to save money for retirement. He’s definitely one of those high achieving, high energy people who we can learn from in our own lives. Imagine a credit union putting forth that kind of effort in its own marketing.
The following is an article reprinted with permission from the upcoming Winter 2010 edition of The WWR Letter:
Recent Updates to Regulation Z
By: V. Kelly Mulholland, Associate
Recently, amendments to Regulation Z, the implementing regulation for the Truth-in-Lending Act (“TILA”) and the Home Ownership and Equity Protection Act (“HOEPA”), became effective. The amendments added a new category of loans. These new loans are called “higher-priced mortgage” loans. The higher-priced mortgage loans include practically all loans in the subprime market. These loans have annual percentage rates (“APR”) above the average prime offer rate for a comparable transaction by at least 1.5 percentage points for first mortgages or 3.5 percentage points for second mortgages.
The rule expands the initial or early disclosure requirements to apply to lenders when their customers purchase a loan for “any extension of credit secured by the dwelling of a consumer.” The disclosure requirements now include home refinance loans, home equity loans and loans to finance the purchase or construction of the consumer’s principal dwelling. The previous rule did not require an initial disclosure to be provided to borrowers on home refinanced loans.
The amendments will affect how a lender does business. Due to the fact that lenders are also prohibited from collecting any fees before the consumer receives the disclosures, except for a fee for obtaining a consumer’s credit report, lenders must deliver or mail the early disclosures at least seven business days before consummation. If the APR contained in the early disclosures becomes inaccurate, lenders must provide revised disclosures reflecting the APR and other disclosures that change so that the consumer receives the revised disclosures at least three business days before consummation. The disclosures must inform consumers that they are not obligated to complete the transaction merely because disclosures were provided or because the consumer has applied for a loan.
Further, the Regulation provides the following restrictions on higher-priced mortgage loans that are secured by a consumer’s principal dwelling:
• The Lender has an affirmative duty to assess the borrower’s ability to repay the loan. The Lender should consider the factors such as the loan-to-value ratio and the borrower’s debt-to-income ratio or residual income at the time the loan is originated.
• Require creditors to verify the income and assets they rely upon to determine repayment ability.
• Ban any prepayment penalty if the payment can change in the initial four years. For other higher-priced loans, a prepayment penalty period cannot last for more than two years.
• Require creditors to establish escrow accounts for property taxes and homeowners insurance for all first-lien mortgage loans.
In addition to the rules governing higher-priced mortgage loans, the rules adopt the following protections for loans secured by a consumer’s principal dwelling, regardless of whether the loan is higher-priced:
• Bans creditors and mortgage brokers from coercing a real estate appraiser to overestimate a home’s value.
• Bans “abusive” servicing practices. Companies that service mortgage loans are prohibited from certain practices, such as pyramiding late fees (taking late fees from regular payments leaving a part of the scheduled payment overdue). Also, Servicers are required to credit consumers’ loan payments as of the date of receipt and provide a payoff statement within a reasonable time of request.
• Creditors must provide a good faith estimate of the loan costs, including a schedule of payments, within three days after a consumer applies for any mortgage loan secured by a consumer’s principal dwelling, such as a home improvement loan or a loan to refinance an existing loan. Currently, early cost estimates are only required for home-purchase loans.
Because of the significant changes to the regulations, Lenders should review the regulations and must ensure that their TILA disclosures and their policies and procedures are revised to comply with these changes.
V. Kelly Mulholland is an Associate in the Litigation & Defense department of the Philadelphia office. He can be reached at (215) 599-1500 or vmulholland@weltman.com.
The following is an article reprinted with permission from the upcoming Winter 2010 edition of The WWR Letter:
New HOEPA Rule
By: David A. Wolfe, Associate
In 1994, Congress enacted the Home Ownership and Equity Protection Act (“HOEPA”), responding to allegations of abusive lending practices in the home-equity lending market. HOEPA applies to closed-end loans on owner-occupied primary residences and non-purchase money transactions, and requires creditors to disclose and comply with limitations in home-equity loan rates and fees.
The Federal Reserve System recently issued significant new mortgage rules that took effect on October 1, 2009. For a newly defined category of higher-priced mortgage loans, the new rule adds protections and enhances existing protections for HOEPA loans, the strongest of which are aimed at curbing questionable lending practices in the subprime mortgage market. However, the definition excludes home equity lines of credit (“HELOCs”), reverse mortgages, construction-only loans and bridge loans. As the definition excludes HELOCs, lenders are prohibited from structuring closed-end transactions as a HELOC where there is no reasonable expectation that repeat transactions will occur.
Under HOEPA, a mortgage is defined as a “High Cost Loan” if it includes certain fees and interest rates that exceed a defined threshold. Covered loans include:
A first lien loan where the annual percentage rate (“APR”) exceeds the rates on comparable Treasury securities by more than eight percentage points;
A junior lien loan were the APR exceeds the rates on comparable Treasury securities by more than ten percentage points;
The total fees and points paid by the borrower exceed eight percent of the total loan amount.
The APR and fee-based triggers include amounts paid at closing for optional credit life, accident, health or loss of income insurance and other credit protection products purchased in connection with the loan transaction.
Where a loan exceeds these thresholds, a lender must disclose to the borrower all pertinent loan terms and any change in terms, at least three days prior to closing.
In addition to the disclosure requirements, the new rules prohibit the following practices:
Balloon payments on loans having a term of less than five years;
Negative amortization payments and capitalized unpaid interest;
Pre-paid payments. Loan terms may not include more than two payments that are consolidated and paid in advance from the loan proceeds provided to the borrower;
Most prepayment penalties;
Due-on-demand clauses. Exceptions include fraud by the borrower in connection with the loan or other defined default;
Default interest rates that exceeds the rate in effect prior to default;
Lenders are also prohibited from approving loans based on the property value without regard to the borrower’s ability to repay the loan, requiring lenders to confirm borrowers’ repayment ability by examining current and reasonably expected income, employment, assets, current obligations and mortgage-related obligations, including property taxes and insurance. The rule does include lender safe harbor practices, permitting lenders to use reasonably reliable evidence of employment, such as information on a W-2 Form, tax returns, payroll receipts and other information from the borrower or borrower’s employer.
HOEPA coverage is based not only on the loan interest rate, but also on points and fees charged by the lender. The effect of these changes may be that more loans exceed the HOEPA thresholds, subjecting many to additional disclosure requirements and restrictions. Additionally, more loans will be covered under state-specific predatory lending laws.
David A. Wolfe is an Associate in the Bankruptcy and Legal Action Recovery departments of the Detroit office. He can be reached at (248) 362-6142 or dwolfe@weltman.com.
Filed under: Credit CARD Act of 2009, credit unions, CUNA, NCUA, The WWR Letter
The following is an article reprinted with permission from the upcoming Winter 2010 edition of The WWR Letter:
The Credit CARD Technical Corrections Act of 2009: A Victory for Credit Unions
By: Hannah F. G. Singerman, Associate
With much fanfare, President Obama signed the Credit Card Accountability Responsibility and Disclosure Act of 2009 (“Act”) into law on May 22, 2009, responding to the ongoing economic crisis. The Act amends the Truth in Lending Act (“TILA” or “Regulation “Z”) by putting further regulations on lenders to purportedly protect consumers.
Upon reading the Act, credit unions were troubled to notice that some important parts of the Act could cause great unintentional burdens on the credit union industry. Specifically, Section 106(b) of the Act which amended TILA Section 163, required creditors in “open end consumer credit plan[s]” to mail periodic billing statements to the consumer no later than 21 days prior to the payment due date. Compliance with Section 106(b) was required within 90 days after enactment or August 20, 2009.
Based on the plain language, it was unclear whether the section applied only to credit cards or to all open-end consumer credit plans such as home equity lines of credit, signature loans, lines of credit connected with checking accounts and, importantly to the multi-featured, open-end lending programs used by credit unions. If the Act did apply to all such plans, many worried that credit unions would struggle to comply under the short notice and in certain cases, compliance would prove difficult in general.
In response, advocacy groups, such as CUNA, lobbied for clarification. In fact, on July 7, 2009, CUNA itself wrote an official comment letter on the bill. The letter asked for clarification as to what type of loans were implicated by Section 106(b). The CUNA letter also urged, that if all open-end consumer credit plans were intended to be covered by the section, then credit unions should be given additional time to come into compliance. Credit unions themselves were urged to write their own official comments to protect the industry.
CUNA, NCUA and others in the credit union industry met with staffers in Washington to inquire about the purpose of Section 106(b) to learn whether the provision was only intended to regulate credit cards. After the comment period on the Act had ended, the House of Representatives passed the Credit CARD Technical Corrections Act of 2009 on October 13, 2009. The Senate passed the legislation on October 29, 2009 and the bill was signed, with much less fanfare than the original Act, by the President on November 6, 2009. The Credit CARD Technical Corrections Act of 2009 is very short, a mere nine lines of text. However, those nine lines make a big impact since they change the term “open end consumer credit plan” in Section 163(a) of TILA as amended by Section 106(b) of the Act to “a credit card account.” For credit unions, this makes all the difference.
The Credit CARD Technical Corrections Act of 2009 is a happy ending for credit unions and a testament to the hard work of so many in the industry.
Hannah F.G. Singerman is an Associate in the Complex Collections department of the Cleveland office. She can be reached at (216) 685-1162 or hsingerman@weltman.com.
The following is an article reprinted with permission from the upcoming Winter 2010 edition of The WWR Letter:
From Crazy Innovations to the Old Standbys
By: Rob Rutkowski, Partner
I cannot remove the magic bullet problem from my mind. It’s like an earworm of a song that will not leave. I’m talking about finding a new revenue producing vehicle for credit unions that will replace overdraft services.
The answer seems to be that there is no magic bullet. Clearly, though, overdraft services itself is a magical product. I certainly would never have guessed that it would have been the runaway success that it was. This is why I’m in my office in Cleveland and not sitting on a beach in Key West. I would never have figured out that something that members could get much more cheaply through a line of credit on their share draft account could be made to be so profitable. I still don’t really get it.
But whatever. Here we are and the goose is dying a slow death by regulation. What to do? Well, there are a couple of things a CEO could try. One of them is to look at some of the more cutting edge services out there. Give a Gen Y’er the ability to point his iPod at a gas pump and pay for the gas out of his share draft account. Let your members scan their checks at home and deposit them at the credit union via email. Give the member the electronic perception that the credit union is available to him or her whenever he or she needs it 24 hours a day. Envelop them in the soft, warm and fuzzy blanket of credit union security. If a credit union can do these things, it can bring in the young people, which is always the key to the future.
Yet there’s money in the old standbys too. What have we got? Indirect lending, mortgages, member business loans, student loans, credit cards, signature loans, direct collateral loans, payday alternatives. This stuff is not new, but does every credit union have them all? If you don’t, add some of them in 2010. Are all of them for every credit union? Not without some preparation. Take indirect lending: you have to monitor the loans so that the dealers don’t kill you with bad paper. You also cannot have the expectation that you’re going to get full service members out of the deal. You’re not. You’re only going to get members who have their car loans with you. But it is still worthwhile if you manage it correctly.
Because of all the problems in the subprime market, there’s opportunity in the mortgage lending world. It’s not perfect either. Interest rates are low and home values are down. But again, if a credit union keeps its costs down and manages the portfolio, it can make money.
Sure there are some barriers to doing commercial loans: you need an underwriter with at least two years experience; the paper is completely different and if a big MBL goes south, you really feel it. Yet, again, these barriers can be overcome with good planning, policies and management. Done correctly, commercial loans are very profitable. 2010 might be a good time to start doing them.
More credit unions are into student loans now than ever before. Using a vendor can make it much easier. Credit cards are a nightmare of new disclosures, but if you buy the forms and disclosures, it can still work nicely. Signature loans are never going to go away and are probably under-marketed by credit unions today. Direct collateral loans could see a come-back even outside the auto market. Remember the computer loan? That’s how I bought my first computer back in the ‘80s. Heck, now credit unions could do direct collateral loans on solar panels and windmills for home use.
You don’t have to add all this stuff in a week. That’s what your planning session is for. Get everyone on board, set up a calendar of what you want to accomplish in 2010 and make daily progress toward your goals. If you plan now not to derive as much of your revenue from overdraft services in 2011 and you are exploring the things I’ve discussed and more, the odds of success will be in your favor.
Rob Rutkowski is the Managing Partner of WWR’s Credit Union department. He can be reached at (216) 739-5004 or rrutkowski@weltman.com.
